Corrective Action Plans

Finding #2025-3 Planned Corrective Action and Status Update CLBL agrees with the finding regarding records retention and documentation controls. However, CLBL does not agree with the refence to a missing “Federal grant agreement.” The documentation in question consisted of two amendments associated with staff changes at USDA and did not materially affect the grant funding, allowable costs, or expenditures. CLBL will strengthen its records retention procedures by maintaining centralized electronic copies of grant agreements, amendments, and supporting documentation. As full system migration was completed in December 2025, supporting documentation is fully intact for future audits. a) Anticipated completion date: December 31, 2026; ongoing thereafter b) Responsible Contact Person: IsaMarie McIntyre

HSDD management is committed to strengthening internal controls over participant eligibility documentation, HAP payment support, annual reexaminations, rent-reasonableness determinations, and HUD-50058 reporting. These efforts will include reviewing the identified exceptions, working to retrieve any outstanding documentation from prior records or service providers, enhancing supervisory oversight, and providing additional training to program personnel. HSDD management recognizes the documentation deficiencies identified during the audit, the absence of supporting documentation does not necessarily establish that the underlying participants were ineligible or that HAP payments were improperly calculated. Accordingly, management intends to review the identified exceptions and work with the appropriate parties to resolve questioned costs in accordance with HUD's final management decision. HSDD management, specifically its Director Dorian Rawles, remains committed to implementing corrective actions designed to improve documentation retention, strengthen program compliance, and reduce the likelihood of similar findings in future reporting periods.

As stated, CERB is in the process of changing the inhouse personnel in charge of the FEMA grants and the COR3 DRS portal. The person assigned will be properly trained in the use of DRS application and will be attending a grant seminar to better acquaint themselves with processes and compliance under 2 U.S. Code of Federal Regulations Part 200. It will be the individual’s responsibility to oversee and monitor the grant managers timely performance, including the timely submission and retention of any required reports.

The City will implement procedures to obtain, review, reconcile, and retain supporting documentation for all Federal award activity, including costs paid on the City's behalf by the Ohio Department of Transportation. Responsibility for monitoring and documenting these activities will be assigned to appropriate personnel, and management will review and reconcile the amounts reported on the Schedule of Expenditures of Federal Awards to the information provided by ODOT.

Management will establish and implement written procedures for documenting personnel activity charged to federal awards. Each employee whose compensation is charged to a federal award will complete an after-the-fact monthly record reflecting their total compensated activity across federal and non-federal work. Each employee's activity record will be reviewed and approved by the Deputy Director, except that the Deputy Director's activity record will be reviewed and approved by the President, monthly. Personnel allocations charged to federal awards will be reconciled to payroll at least quarterly. The Organization will retain the records and use documented actual activity, rather than budget estimates, as the basis for allocating personnel costs to federal awards.

FINDING 2025-023 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Jenna Harrington, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jharrington@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A comprehensive Internal Controls Manual was written and released in December 2024 with implementation beginning July 1, 2025. This includes segregation of duties, purchasing processes, contacts process, grant processing, Grant Reimbursements The reimbursement process was updated to include all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a recurring basis, the Director of Federal Grants generates the detailed expenditure report and budget summary. The detailed report is filtered to capture only the transactions occurring since the previous reimbursement request, making new expenditures easy to identify. These amounts are added to the cumulative reimbursement totals, which are then compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request is reviewed by the Chief Financial Officer and submitted to the awarding agency. Since there was no reimbursement form for this grant, the supervisor review signature was not always collected. It has been added on one of the sheets within the supporting documents of the packet. Financial Reporting Reviewing The fiscal officers managing the grant will have their supervisor review financial reports prior to submission and sign their approval. Anticipated Completion Date: July 1, 2025

CORRECTIVE ACTION PLAN FINDING 2025-022 Finding Subject: Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal Control Manual: Released a comprehensive manual covering segregation of duties, purchasing, and grant management. Reimbursement & Reporting Oversight: Added explicit supervisor review signatures to grant packet supporting documents and financial reports prior to final agency submission. Anticipated Completion Date: Grant Ended: December 2025 IC Updates: January 1, 2025

FINDING 2025-020 Finding Subject: Education Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Vendor Service Contracts: Standardized contract guidelines for all non-employee services. Contracts must specify exact rates, hours, duration, maximum billing limits, and include standard legal terms. Approval Hierarchy: Contracts under $50,000 can be preliminarily approved by the Superintendent and later presented to the Board. Contracts over $50,000 require a dedicated Board presentation and approval. Contract Procurement Rules: Enforced tiered purchasing thresholds—Micro Purchases (no quote), Small Purchases (3 quotes required), and Large Purchases (bid process). Change Orders: Requires formal documentation and approval. Any change order increasing project costs by 10% or more requires pre-approval from the School Board.

FINDING 2025-014 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Condition of Records Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. This grant is no longer in use. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

FINDING 2025-012 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Allowable Costs / Cost Principles Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Contract Retention: HR and Regional Data Services updated software archives to prevent loss of administrative records. Grant Personnel Verification: Grant fiscal officers must review and sign Payroll Certification Reports to confirm payroll accuracy for employees charged to the grant. Payroll & Overtime Controls: All employee compensation must receive prior School Board approval. Implemented a formal 10-step stipend approval workflow and mandated pre-approval for all overtime hours. Anticipated Completion Date: Completed by June 30, 2026

FINDING 2025-008 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Bo Yan, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, byan@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: • Centralized enrollment/withdrawal document management with weekly accuracy audits. • Updated Internal Control Manual to mandate a 12-item list of enrollment documents (birth certificates, residency proof, immunizations, etc.). • Established a formal "Summary of Attempts" process requiring at least 3 documented attempts to secure residency proof before submitting signed summaries. • Standardized documentation for general transfers, mandatory 16–17-year-old exit interviews, and Title I ESSA graduation cohort tracking. Anticipated Completion Date: January 1, 2027 (Note: Specific student mobility updates corrected April 1, 2026).

FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Data & HR Retention: Updated software stores and archives via Regional Data Services to prevent administrative record loss. Payroll & Compensation: Enforced required School Board pre-approval for all compensation. Instituted a formal 10-step stipend approval workflow and mandated supervisor pre-approval for all overtime hours. Supporting Documents: Human Resources is responsible for saving and maintaining all personnel requisitions and contracts. Overtime Policy: Mandates supervisor pre-approval before overtime hours are worked Anticipated Completion Date: Corrected 06/30/2026

CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster –Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: James Lutaaya, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jlutaaya@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Human Resources worked with Regional Data Services to identify the cause of the issue and made corrections to prevent the data being lost on the administrative side moving forward. This involved updates to software stores and archives. PAYROLL EXPENDITURES All compensation an employee receives must go before the School Board for approval prior to the pay. Approvals are retained in the form of Personnel Requisitions, Union Contracts, Board Personnel Approval. Pay Change Process: Stipend Approval Process: STEP ACTIVITY PRIMARY EMPLOYEE LEVEL REVIEWED BY NOTE 1 Create Employee Change Personnel Requisition (in Applicant Tracker or on paper) Employee's Supervisor School / Department Department Supervisor Be specific and fill in all fields. 2 Submit to the Department Supervisor for Review & Approval Employee's Supervisor School / Department Department Supervisor 3 Submit to Human Resources for Review & Approval Department Supervisor Central HR HR will review to ensure compliance with approved salary and job titles 4 Submit to Finance for Review & Approval HR Central Finance Finance will verify vacant positions exists and provide funding information. 5 Submit to Human Resources for Processing Finance Central HR HR will update the employee's information in financial / employee software 6 Verify Accuracy of Updates HR - 2nd employee Central n/a 7 Save a Copy of all Requisitions HR Central n/a 8 All pay changes are included in the Personnel Report that is submitted to the Board to obtain approval. HR Central School Board This includes position changes, job title changes, raises, transfers, etc. INDIANA STATE BOARD OF ACCOUNTS 88 OVERTIME APPROVAL POLICY All overtime hours must receive prior approval from a supervisor or manager before extra hours are worked. Employees are not permitted to work overtime without explicit approval, except in emergency situations where prior approval is not feasible. Failure to obtain approval may result in the overtime hours being unpaid or other disciplinary actions. To request overtime, employees must submit a request to their supervisor with a brief explanation of the need for additional hours. Approval will be granted based on workload requirements and budget considerations. Corrected Date: 06/30/2026 INTEGRITY • ACCOUNTABILITY • EMPOWERMENT ACADEMIC QUALITY | EQUITY, INCLUSION & JUSTICE | FINANCIAL SUSTAINABILITY | COMMUNITY PARTNERSHIPS 737 Beale Street • South Bend, Indiana 46616 • 574-393-6100 • sb.school

2025-002 – Subrecipient Monitoring Corrective action plan: 1. The subaward template was corrected in September 2026 and is in use. The corrected form was used for the subaward executed September 18, 2026 and carries the full set of federal award identification elements required by 2 CFR 200.332(b)(1). 2. Obtain the current unique entity identifier for each subrecipient from SAM.gov and confirm it against subrecipient records. 3. Issue Modification No. 1 to each of the seven Round 1 subaward agreements, adding the Assistance Listing Number and title, the subaward budget period start and end dates, and the unique entity identifier where it was omitted, and issue an amended award notification supplying the same information for the Round 1 award made by award letter. Article IV, Section 6.11 of each subaward agreement permits NFEAIE to issue non-substantive modifications unilaterally in writing, so issuance is not contingent on subrecipient countersignature. Each modification will be transmitted to the subrecipient's authorized official and fiscal contact by email and the transmittal retained in the subaward file. 4. Issue Modification No. 1 on the same basis to Round 2 subawards R201 through R206, which were executed on the prior template. 5. Adopt a written subaward issuance procedure incorporating a checklist of the information required by 2 CFR 200.332(b)(1), completed, signed, and retained in the subaward file before execution, with CFO review of the executed instrument required before any disbursement. Personnel responsible for corrective action: Nicholas Cunningham, CFO Estimated corrective action completion date: November 30, 2026

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that employee compensation approvals were not consistently performed in accordance with documented procedures. To strengthen segregation of duties and oversight, responsibility for review and approval of employee compensation changes will be reassigned to appropriate executive leadership personnel independent of payroll processing responsibilities, consistent with the requirement under the Uniform Guidance (2 CFR 200.303) that the Organization establish and maintain effective internal control over federal awards. All pay raises will be initiated upon the recommendation of the respective department directors and must be approved by the Chief Executive Officer (CEO) or Chief Financial Officer (CFO) prior to processing. All compensation changes will be made in accordance with the Organization's Board-approved written compensation policies and will be reasonable and consistent with compensation paid for similar work, as required by the compensation standards for personal services under the Uniform Guidance (2 CFR 200.430). Human Resources will be responsible for ensuring that all pay raise documentation, including department director recommendations and CEO/CFO approvals, is properly completed and filed in the employee’s personnel record. Documentation of all compensation approvals will be maintained in accordance with the record retention requirements of the Uniform Guidance (2 CFR 200.334) and periodically reviewed to ensure compliance with established policies and procedures. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30, 2027

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that evidence of review and approval was not consistently retained and that documentation supporting reimbursement requests was not maintained at a level sufficient to demonstrate compliance with federal requirements. To address this deficiency, management is implementing formal documentation standards requiring each reimbursement request to be supported by a reconciliation of amounts requested to actual allowable expenditures recorded in the general ledger, together with documented evidence of reviewer approval. Each reconciliation will be prepared by grant and budget category and will compare cumulative expenditures recorded in the general ledger to cumulative amounts previously drawn through the Payment Management System, with any differences investigated and resolved before the request is submitted. The Chief Financial Officer (CFO) or the Chief Executive Officer (CEO) will then review and approve each Request for Reimbursement form and related reconciliation before submission, consistent with the approval process described in the responses to Findings 2025-003 and 2025-006. Evidence of this review will include the approver’s handwritten or electronic signature and the approval date on both the Request for Reimbursement form and the supporting reconciliation. In addition, all expenditures will require documented preapproval by the respective department director or other designated personnel before costs are incurred. Original receipts, invoices, and other supporting documentation will be submitted to the Accounting Department, which will review each expenditure to verify that it is properly authorized, adequately supported, accurately coded, and incurred for a legitimate business purpose of the Organization. Prior to the submission of any reimbursement request, expenditures charged to federal awards will be reviewed for allowability, allocability, reasonableness, and adequate documentation in accordance with the cost principles of the Uniform Guidance (2 CFR Part 200, Subpart E). All reconciliations, approvals, and supporting documentation will be retained in accordance with federal record retention requirements and made readily available for review. Supporting documentation will be maintained in a centralized location, organized by grant and reimbursement period, and retained in accordance with the Uniform Guidance record retention requirements (2 CFR 200.334). The Organization will incorporate these review and approval procedures into its written financial policies and procedures, and finance staff involved in preparing reimbursement requests will receive training on them. In addition, management will periodically perform a secondary review of a sample of completed reimbursement requests to verify that reconciliations, approvals, and supporting documentation are complete, and any exceptions identified will be promptly corrected and documented. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges deficiencies in controls over payroll allocation processes and recognizes the importance of ensuring compensation costs charged to federal programs are supported by records reflecting actual work performed. Management is implementing revised payroll allocation procedures requiring allocations to be supported by approved time records and documented review processes. Specifically, compensation charged to each federal award will be based on timesheets or other time and effort records that reflect the actual hours worked on each program, are signed by the employee, and are approved by the employee’s direct supervisor, in accordance with the standards for documentation of personnel expenses under the Uniform Guidance (2 CFR 200.430(g)). Overtime will require advance supervisory approval and will be charged only to the program on which the overtime hours were worked. Additional training will be provided to employees and supervisors regarding timekeeping and grant coding requirements, and management will periodically review payroll allocations to verify compliance with federal requirements. Each pay period, the Accounting Department will reconcile payroll allocations recorded in the payroll system to approved time records before posting related costs to the general ledger and charging them to federal programs, and will investigate and correct any discrepancies before including the costs in a reimbursement request form. Where budgeted allocations are used for interim purposes, they will be compared to actual effort at least quarterly and adjusted as necessary so that final amounts charged to federal awards reflect actual work performed. The Chief Financial Officer (CFO) will review the results of these reconciliations, and all time records, approvals, and reconciliations will be retained in accordance with the record retention requirements of the Uniform Guidance (2 CFR 200.334). Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that documentation supporting certain expenditures charged to federal programs was not adequately maintained and that review procedures over reimbursement requests were not sufficient to ensure expenditures were fully supported and accurately reflected. Management is implementing enhanced procedures requiring all expenditures included in reimbursement requests to be supported by source documentation and reconciled to accounting records prior to submission. The Accounting Department will collect original invoices, receipts, payroll registers, and other source documents when costs are incurred, and will prepare reconciliations using final invoices rather than estimates, quotes, or purchase orders. In limited circumstances where an estimate must be used for anticipated expenses, the basis for the estimate will be documented and approved prior to submission, and the estimated amount will be reconciled to actual expenditures in a timely manner, no later than the subsequent reimbursement request, with any differences promptly adjusted and supporting documentation retained. In addition, independent review procedures will be performed to verify allowability, accuracy, and completeness before federal reimbursement requests are submitted. Each reimbursement request will then be reviewed and approved by the Chief Financial Officer (CFO) or the Chief Executive Officer (CEO) before submission, consistent with the approval process described in the response to Finding 2025-003. The Organization will organize supporting documentation by grant and reimbursement period and retain it in accordance with the record retention requirements of the Uniform Guidance (2 CFR 200.334). Additionally, the Chief Financial Officer (CFO) will perform periodic sample-based reviews of expenditures charged to federal awards to verify that documentation standards are consistently followed, and any exceptions identified will be promptly corrected, including adjustment of amounts previously requested where necessary. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

1. MISSING INVOICES During a change of fee accounts, invoices for January, February, & March 2025 were lost in mail. We now scan all invoices directly to accountant.

Continuum of Care -Assistance Listing No. 14.267 Recommendation: Share & Care should strengthen document retention and disbursement review procedures by implementing a centralized filing system for invoices, lease agreements, and supporting documentation. Management should require all supporting documents to be electronically maintained and attached to each disbursement batch prior to approval. In addition, periodic reviews should be performed to ensure documentation is complete, properly organized, and readily accessible for compliance and audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Share & Care House has strengthened its document retention and disbursement review procedures by implementing comprehensive policies and procedures governing the retention of invoices, lease agreements, client files, and all supporting documentation. Following approval, all supporting documentation is electronically scanned and retained in a secure server location. This location is a restricted administrative location with limited access to protect records from accidental deletion or unauthorized modification and to ensure long-term retention. Original paper documentation is maintained with each program's client files, master lease files, or invoice packets in accordance with the organization's record retention policy. Management conducts periodic reviews to verify that documentation has been properly retained, is complete, and is readily accessible for monitoring, compliance, and audit purposes. These procedures strengthen internal controls over document retention, improve the accessibility of supporting documentation, and ensure compliance with HUD record retention requirements. These corrective actions establish a centralized document retention process, strengthen internal controls over disbursements, and ensure supporting documentation is maintained in compliance with HUD record retention requirements. The Co-Executive Directors will conduct periodic reviews of disbursement packets and electronic files to verify that supporting documentation is complete, properly retained, and available for compliance reviews and future audits. Name(s) of the contact person(s) responsible for corrective action: Sheera Smith Planned completion date for corrective action plan: September 2026

Noncompliant Buy America Procurements - Transit - MDT - The Montana Department of Transportation is strengthening internal controls and ensuring full compliance with federal requirements for procuring public transit vehicles. The Transit Section and the Procurement Unit are jointly developing comprehensive procedures that clearly define roles and responsibilities, update procurement checklists, and establish a centralized location for maintaining complete procurement files. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026

Inadequate Suspension and Debarment Verifications - Transit - MDT - The Montana Department of Transportation concurs with the finding. A. The Transit Section and Procurement Unit are jointly developing comprehensive procedures that clearly define roles and responsibilities, update procurement checklists, and establish a centralized location for maintaining complete procurement files. These updated procedures will be completed by the end of calendar year 2026. B. The Procurement Unit and the Legal Office began working together in July 2026 to review all templates, clauses, and federal requirements. This review will be ongoing to ensure compliance with all state and federal regulations. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026

Noncompliant Annual Reporting Controls - ESSER - OPI - The Montana Office of Public Instruction concurs with the finding. The grant is closed, and the temporary grant-funded staff are no longer with the agency. Moving forward, new grant managers will receive clearer direction on the agency’s internal controls. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026

Condition During testing of cash disbursements, the audit team was unable to locate adequate supporting documentation for selected transactions sufficient to determine whether the costs charged were allowable and the activities were allowed under the applicable federal award(s). Documentation such as invoices, receipts, contracts, approvals, or evidence linking the expenditure to an allowable activity could not be located or provided by the Institute. Criteria Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and adequately documented. Per 2 CFR § 200.302 and § 200.334, non-federal entities must maintain financial records, including source documentation (e.g., invoices, receipts, canceled checks, time and effort records) that support the allowability, allocability, and reasonableness of costs charged to federal awards, and these records must be retained and readily accessible for a minimum of three years. Additionally, 2 CFR § 200.404 and § 200.405 require that costs be allocable and consistently applied to allowable program activities. Cause The Institute's recordkeeping and document retention practices did not ensure that supporting documentation for cash disbursements was consistently maintained, organized, or readily retrievable. This may be attributable to insufficient internal controls over document retention, lack of a centralized filing/records system, or turnover in staff responsible for maintaining disbursement records. Effect Without adequate supporting documentation, the Institute cannot demonstrate that disbursed funds were used for allowable costs and allowed activities in accordance with the terms of the federal award(s). This exposes the Institute to the risk of questioned costs, disallowed expenditures, required repayment to the funding agency, and potential findings of noncompliance in future audits. It also limits the Institute's ability to demonstrate accountability and stewardship over federal funds. Recommendation We recommend that the Institute strengthen internal controls over cash disbursements to ensure supporting documentation (invoices, receipts, approvals, and evidence of allowable activity) is obtained and retained for every transaction prior to disbursement. The Institute should implement a centralized, organized recordkeeping system (physical or electronic) for disbursement documentation, with clear responsibility assigned for maintenance and retrieval. The Institute should also provide training to relevant staff on documentation retention requirements under 2 CFR Part 200. Management’s Response Management agrees with the finding and recommendation. The Institute recognizes that complete and readily retrievable supporting documentation is necessary to demonstrate the allowability, allocability, and reasonableness of costs charged to all awards. Management will strengthen its cash disbursement and record-retention procedures to ensure invoices, receipts, approvals, contracts, and other applicable supporting documentation are maintained for each transaction. Action Taken The Institute implemented a centralized electronic recordkeeping process for cash disbursement documentation and assigned responsibility for maintaining and retrieving supporting records. Documentation supporting the expenditure and applicable approvals are retained with the transaction records. Relevant staff have been instructed on documentation and record-retention requirements applicable to federal awards. Management will hold an annual training at the beginning of the new fiscal year available to all ERI employees.